COVID-19 Specimen Collection and Testing

How to code Medicare Part B claims for reimbursement.

The American Medical Association (AMA) released a new proprietary laboratory analysis (PLA) code for novel coronavirus testing. This code is to be used specifically to report the BioFire® Respiratory Panel 2.1 test.

Let’s Review

With yet another testing code, you may be a little confused as to which code to use for what test. Here’s a rundown of the COVID-19 clinical diagnostic laboratory testing codes, with effective dates and Medicare payment rates.

*$35.92 in MAC A/B JH, JL, JN, JS, J8, J15

Update: CMS added the QW modifier to HCPCS Level II U0002 and CPT® 87635. Medicare will allow the use of U0002QW and 87635QW for claims submitted by facilities with a valid, current CLIA certificate of waiver with dates of servcie on or after March 20, 2020. (MLN Matters MM11765)

The effective date for 0202U, per the AMA, is May 20, 2020. The Centers for Medicare & Medicaid Services (CMS) has not weighed in on this new code, as yet. In an earlier FAQ, CMS says to use HCPCS Level II code U0002 for COVID-19 test methods that are not specified by either HCPCS Level II U0001 or CPT® 87635.

See the CPT® Assistant Special Edition May Update for more details on how the AMA intends us to use this new code. See also the CPT® Assistant Special Edition April Update for the AMA’s guidance on using 86328 and 86769. (Note: CPT® Assistant is a paid subscription service. These special editions, however, are free and available for download on the AMA’s website.)

Ordering COVID-19 Diagnostic Lab Tests

During the public health emergency (PHE) for COVID-19, CMS has removed the requirement that certain diagnostic tests are covered only under the order of at treating physician or nonphysician practitioner (NPP). Any healthcare professional authorized to do so under state law may order COVID-19 diagnostic lab tests.

Specimen Collection

Medicare will allow payment for COVID-19 specimen collection billed by qualifying practitioners with CPT® code 99211 Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services.

Use CPT® 99211 to bill for a COVID-19 symptom and exposure assessment and specimen collection provided by clinical staff incident-to the supervising physician’s or NPP’s services.

UPDATE:
Contact your Medicare Administrative Contractor if you did not include modifier CS when you submitted 99211 so they can reopen and reprocess the claim. CMS will automatically reprocess claims billed for 99211 that were denied due to place of service editing. (MLN Connects June 18, 2020)

Hospital outpatient departments should use HCPCS Level II code C9803 Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV2) (coronavirus disease [COVID-19])), any specimen source to be paid for COVID-19 symptom assessment and specimen collection.

Note:
HCPCS Level II code C9803 is effective for services provided on or after March 1, 2020. Outpatient Prospective Payment System (OPPS) claims receive on or after May 1, 2020 with coronavirus specimen collection codes G2023 and G2024 will be returned with edit W7062. Resubmit returned claims as a packaged service to include C9803, as appropriate. (MLN Connects May 7, 2020)

Independent labs may bill Medicare for specimen collection fees, transportation fees, and personnel expenses for the duration of the PHE for COVID-19. These fees are billable if the specimen is collected by trained lab personnel from a homebound or non-hospital inpatient. These fees and expenses are not billable if the patient collects their own specimen and a messenger service picks it up.

Price Transparency Requirements

Providers of diagnostic tests for COVID-19 are required to post on their website how much they will charge a patient for the service. This requirement, enacted in section 3202(b) of the CARES Act, is effective for the duration of the PHE for COVID-19. Medicare patients should not be charged a deductible or copay for any COVID-19 test.

Resources:

CMS COVID-19 FAQ on Medicare FFS Billing

https://www.ama-assn.org/system/files/2020-05/coronavirus-long-descriptors.pdf

https://www.cms.gov/files/document/mac-covid-19-test-pricing.pdf

CMS MLN Matters 11805

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Renee Dustman

Managing Editor at AAPC

Renee Dustman, BS, AAPC MACRA Proficient, is managing editor - content & editorial at AAPC. She holds a Bachelor of Science degree in Media Communications - Journalism. Renee has more than 30 years' experience in journalistic reporting, print production, graphic design, and content management. Follow her on Twitter @dustman_aapc.

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